Under the Table, On the Radar: Improving Anti-corruption Compliance for Financial Services Institutions

August 2011


Around the globe, calls for increased anti-corruption initiatives and enforcement are continuing to expand and intensify. Financial services institutions are increasingly coming under scrutiny by regulators, with the number of anti-corruption cases and severity of penalties expected to continue to increase. This focus on corruption is supported by, among others, the Dodd-Frank Wall Street Reform and Consumer Protection Act, which creates new enforcement functions and whistleblower incentives, and the UK Bribery Act, which is expected to have serious implications for all financial institutions that operate within the UK, even those based in other countries. In addition, 140 countries have signed on to the United Nations Convention Against Corruption and are beginning to implement its required enforcement.

The new anti-corruption era is driving companies to change their behaviors to adapt to greater financial and reputational risks. At the same time, grey areas—including facilitation payments, travel and entertainment expenses, and the retention of third-party agents—add to the burden of anti-corruption compliance. While companies have made progress, executives continue to acknowledge that their anti-corruption programs need to do more to deter and detect corruption. Leading financial institutions are demonstrating that an effective anti-corruption program must continually reassess risks and be supported by consistent, clear messaging from the top.


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Manny A. Alas
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